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In addition to the items specifically proven by respondent,
petitioners conceded numerous adjustments determined by
respondent to be unreported income or deductions to which
petitioners were not entitled.
To the extent no settlement or concession was made regarding
any other item determined by respondent, petitioners have not
come forward with arguments or evidence from which we could find
that respondent’s determinations are in error. Regarding the
fraud penalty, respondent has shown by clear and convincing
evidence that petitioners' underpayments of 1989 tax were due to
fraud.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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